Data Processing Agreement (DPA)

Effective Date: [Insert Date]

This Data Processing Agreement (“Agreement” or “DPA”) is entered into between Closet Cache, LLC, a company registered in the United States with principal business address at [Insert Legal Address] (“Company”, “we”, “us”, or “our”), and the user of Closet Cache’s services (“User”, “you”, or “your”), and governs our processing of personal data on your behalf in connection with our services.

This Agreement is incorporated by reference into our Terms of Service and Privacy Policy, and is intended to ensure compliance with applicable data protection laws, including:

  • General Data Protection Regulation (EU) 2016/679 ("GDPR")

  • California Consumer Privacy Act (CCPA), and CPRA

  • Applicable U.S. federal and state data privacy laws

1. Definitions

"Personal Data" means any information relating to an identified or identifiable individual processed by the Company in connection with its services.

"Processing" means any operation performed on Personal Data, whether automated or not, such as collection, use, access, storage, or deletion.

"Processor" means Closet Cache as the entity processing Personal Data on behalf of its users.

"Sub-processor" means a third party engaged by Closet Cache to process Personal Data.

"Data Controller" refers to the user when they upload, list, or manage their information through the Site.

2. Roles and Scope

Closet Cache acts as a Data Processor on behalf of its users, who may act as either Data Controllers or Data Subjects, depending on the context (e.g., buyers, sellers, or visitors).

This DPA governs the processing of Personal Data by Closet Cache and its authorized Sub-processors in connection with providing services through https://www.closetcache.shop.

3. Data Processing Details

  • Purpose: To provide and support the Closet Cache platform and services.

  • Nature: Collection, storage, analysis, transmission, and deletion of user data.

  • Categories of Data Subjects: Site visitors, registered users, buyers, and sellers.

  • Categories of Personal Data:

    • Identification info: name, email, phone, delivery address;

    • Transaction data: purchase records, payment method (limited to tokens);

    • Account preferences and communication history;

    • IP address, location (if provided), and device/browser data.

Closet Cache does not collect or process:

  • Sensitive personal information (e.g., health, religion, biometric data);

  • Children’s data (under age 18);

  • Government-issued IDs.

4. Sub-processors

Closet Cache uses third-party Sub-processors to deliver its services, including but not limited to:

  • Stripe, Inc. – Payment processing

  • Shopify, Inc. – E-commerce infrastructure

  • Google Analytics – Website analytics

  • SendGrid / Mailchimp – Email communications

  • Shippo / EasyPost – Shipping logistics

  • Cloudflare / AWS – Hosting & CDN

We maintain agreements with all Sub-processors to ensure they provide an equivalent level of data protection.

You will be notified of any material changes to our Sub-processor list and have the right to object to new Sub-processors if they materially impact your data protection rights.

5. Data Subject Rights

Closet Cache shall assist in responding to requests from Data Subjects regarding:

  • Access to personal data;

  • Rectification or erasure;

  • Restriction or objection to processing;

  • Portability of personal data.

All such requests can be directed to privacy@closetcache.shop, and we will respond within legally required timeframes.

6. Security Measures

Closet Cache implements appropriate technical and organizational measures to protect Personal Data, including:

  • HTTPS encryption;

  • Access controls;

  • Secure storage and transmission;

  • Data minimization and retention limits.

In case of a data breach, we will notify affected parties without undue delay, in accordance with applicable law.

7. Data Transfers

Personal Data may be processed in the United States or other jurisdictions where Closet Cache or its Sub-processors operate. Any international transfers will be:

  • Covered by appropriate safeguards under GDPR (e.g., Standard Contractual Clauses);

  • Compliant with applicable U.S. federal and state privacy laws.

8. Data Retention and Deletion

Closet Cache retains Personal Data only as long as necessary to fulfill the purpose for which it was collected or as required by law. Users may request deletion of their data by contacting us or via their account settings. Upon account deletion:

  • Data will be securely removed or anonymized within 30 days;

  • Certain data may be retained for legal or tax compliance.

9. Audits and Cooperation

We will provide documentation or information reasonably necessary to demonstrate our compliance with this DPA, upon request. Formal audits may be permitted once per year upon 30 days' written notice, unless required by law.

10. Liability and Indemnity

Closet Cache’s liability for breach of this DPA shall be limited as described in our Terms of Service, except where prohibited by applicable law. Users agree to indemnify Closet Cache for any costs arising from misuse of Personal Data outside of this Agreement.

11. Termination

This DPA shall remain in effect for as long as we process Personal Data on your behalf. Upon termination of services, all Personal Data will be deleted or returned, unless legally required to be retained.

12. Contact

Questions about this DPA or data protection practices may be sent to:

📧 privacy@closetcache.shop
📍 Closet Cache, LLC
[Insert Mailing Address]

📎 Appendix A: Summary of Sub-processors (Optional Table Format)

Sub-processorPurposeLocationSafeguardsShopifyE-commerce infrastructureUSADPA, Standard TermsStripePayment processingUSAPCI-DSS, SCCSendGridTransactional emailsUSADPAGoogle AnalyticsUsage analyticsUSAIP anonymizationEasyPost / ShippoShipping APIsUSASecure APIs